2026 (6) TMI 1158

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....sposed of through a common order. While ITA No.231/Del/2021 emanates from order u/s. 250 of the Income Tax Act, 1961 (hereafter as "the Act"), dated 20.11.2020 passed by Ld. CIT(A), Delhi-42, the appeal in ITA 2171/Del/2023 arises from order u/s. 250 of the Act dated 01.06.2023. While ITA 231/Del/2021 is the substantive appeal, ITA 2171 is an appeal against an order of AO u/s. 154 of the Act. 2. On the last date of hearing, the Ld. AR pointed out the facts of the case and extensively referred to an affidavit dated 05.01.2024 filed by the assessee, who is residing abroad as a US citizen. For the sake of catching the facts some portions from this affidavit may be extracted: - "4. The issue involved in these proceedings is my depos....

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....ted of arrival 19/11/2016 and date of departure 04/12/2016. During my visit to India I found that unutilized cash amounting to Rs. 11,18,500/- was lying with my parents out of the money given to them by me from time to time. Due to the Government Scheme of Demonetization, I had deposited the said amount of Rs. 11,18,500/- in my saving bank account as stated above. During the assessment proceedings the source of cash was provided to Ld. AO but the same was not accepted. AO in one of the reason as stated in the assessment order had stated that in my salary slip in USA placed on record, my designation in job is not defined, whereas the said document contains my designation copy annexed is made part of this Affidavit. 7. It is....